409A and W-2 Reporting

[Guest 2341mid]

I've seen conflicting statements regarding what exactly is supposed to go into Code Y of Box 12 on the W-2. A Paychex bulletin states "employees' annual deferrals", Vanguard states to report "all vested amounts deferred during the tax year from all sources", my ERISA attorney states "all current year deferrals, inlcuding earnings on those deferrals", and finally our friends at the IRS state "Include current year deferrals udners a section 409A NQDC plan. Any earnings during the year on current year and prior year deferrals must also be reports here".

I'm going with what my atty and the Service state. However, it looks like I'll need the help of my recordkeeper to determine the earnings on those deferrals.

I'm kind of shocked at the levels of misinterpretation out there. Has anyone else given any thought to this fun little extra step we now need to get done?

Thanks